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Form ID: 2411
Agent: Axiom Great Barford Limited

1.0 Introduction 1.1 This Issues and Options representation is made on behalf of Axiom Great Barford Limited (‘Axiom’) who have land interests in Great Barford. A separate call for sites submission has been made in relation to the site. 1.2 Axiom are promoting land off Bedford Road, Great Barford on behalf of two landowners and the site can accommodate approximately 350 new dwellings, community facilities, open space and landscaping. 1.3 The site has been promoted for allocation through the Great Barford Neighbourhood Plan which is being developed by the Parish Council to designate land for the 500 homes allocated to the village in the adopted Local Plan 2030. The site has received a favourable assessment by AECOM, the consultants assisting the Parish Council with the Neighbourhood Plan, but at this time the plan has not progressed to the point of setting out a development strategy or proposed allocations. 1.4 Whilst the preference is to work closely with the Parish Council to secure the allocation of the site, Axiom are promoting the merits of the site, and Great Barford in general, as a sustainable location for growth in the Local Plan Review. 1.5 This representation is structured around the 13 questions which are set out in the Issues and Options Paper. However, only those questions that are relevant to Axiom’s land interests have been answered.

Form ID: 2412
Agent: Axiom Great Barford Limited

No

2.1 The main purpose of the Local Plan Review should be to confirm the revised development needs of the area and set out where housing and employment growth should occur. The development management policies in the Local Plan 2030 have only recently been adopted and whilst these should be reviewed to ensure they are consistent with the National Planning Policy Framework (NPPF) 2019, they are likely to generally remain fit for purpose to guide decision making. 2.2 Reviewing the adopted development strategy and making new land allocations to meet the identified housing and employment needs should be the focus of the Local Plan Review, as suggested by the Inspector in finding the Local Plan 2030 sound. 2.3 The list of topics in the Issues and Options document suggests that the Local Plan Review will make such allocations and will have policies to ensure that growth is sustainable and will deliver high quality development. However, the list also suggests a number of far more detailed policy areas, such as the control of fast-food outlets, which is at odds with the suggestion that the main focus will be on growth and infrastructure. 2.4 While Axiom do not have a view of the need for such policy areas to be addressed, these would be better covered in a general review of development management policies to avoid the focus being taken away from the high level spatial issues that are integral to the soundness of the Local Plan Review. This is in line with emerging Government policy set out in the recent Planning/Housing White Paper. 2.5 There are a number of key issues related to the scope of the Local Plan Review and the spatial strategy which are not addressed in the questions on the Issues and Options document. The first of these is the overall quantum of planned housing growth. 2.6 As indicated in the Issues and Options consultation document (page 16), the Standard Methodology currently sets out a minimum housing need of 1,305 dwellings per annum over the period to 2040. The Local Plan Review should seek to provide this level of growth as a minimum but depending on the proposed strategy and the risk to the delivery of allocated sites, the plan should also provide 10-20% additional growth above the current figure to ensure the minimum need is met. 2.7 Whilst the Standard Methodology is under review, it should not be assumed that this will mean the recently published 2018 Household Projections will simply replace the use of the 2014 projections. This is implied in the consultation document, suggesting the Local Plan Review could need to plan for a housing figure as low as 800 dwellings per year. 2.8 Given the Government’s objective of significantly increasing the supply of new homes, alongside the aspirations for the Oxford to Cambridge Arc and the recent announcements in the White Paper about a revised methodology, it is unrealistic to suggest that the Local Plan review should be considering such a low housing figure. 2.9 The scope of the Local Plan Review should therefore be to accommodate a minimum of 15,000 additional homes on top of existing commitments (plus any un-progressed Neighbourhood Plan allocations and a flexibility allowance). If a revised Standard Methodology is introduced and reduces this figure slightly, then the scale of planned growth can be adjusted in due course – this would not be possible if a lower figure were to be planned for. 2.10 The second key issue not fully addressed in the questions is the extent to which the ambitions for the Oxford to Cambridge Arc are considered in the review. Whilst there is currently no Arc-wide spatial strategy, progress has been made on a number of key infrastructure projects in the area and there is a clear intent from the Government to drive forward growth in the Arc. 2.11 As part of the most recent Budget announced in March 2020, it was confirmed that: The government has designated the corridor of land connecting Oxford, Milton Keynes, Bedford and Cambridge (the OxCam Arc) as a key economic priority. Earlier this year, the government announced the East West Rail Company’s preferred route for the new line between Bedford and Cambridge…… The Budget announces plans to develop, with local partners, a long-term Spatial Framework to support strategic planning in the OxCam Arc. This will support the area’s future economic success and the delivery of the new homes required by this growth up to 2050 and beyond. The government is also going to examine and develop the case for up to four new Development Corporations in the OxCam Arc at Bedford, St Neots/Sandy, Cambourne and Cambridge, which includes plans to explore the case for a New Town at Cambridge, to accelerate new housing and infrastructure development.” 2.12 It is therefore clear that the Government is firmly committed to the Arc with the expectation being that there will be significant residential development to support the economic potential of the area. 2.13 The Government’s position, alongside the fact that policy 1 of the adopted Local Plan 2030 requires the review to address Arc related issues, suggest that the scope of the Local Plan Review needs to give more emphasis to assessing the implications of Arc related policy announcements and infrastructure investment decisions, particularly as they relate to spatial decisions and the level of planned growth.. 2.14 The Arc strategy is likely to evolve throughout the preparation of the Local Plan Review and it will be important that the Council are in a position to respond positively to any announcements to avoid delay in preparing the Plan, reinforcing the need for greater consideration of Arc related matters in the scope of the review.

Form ID: 2413
Agent: Axiom Great Barford Limited

3.1 As currently drafted, the Vision set out on pages 13 and 14 of the Issues and Options document is too generic with a lack of references to how and where growth will occur across Bedford Borough. 3.2 Whilst is it understood that options still need to be assessed and decisions made about the spatial strategy, Axiom consider that future iterations of the Vision should be more specific and set out more clearly what the area will be like at the end of the plan period. 3.3 Whilst there are references to where growth is already planned in the town centre and to the west of Bedford, there is no reference to the role of other settlements, how they will relate to infrastructure enhancements or how they will contribute to the overall aspirations for the Borough. This is an omission that will need to be amended in future iterations of the Vision. 3.4 There is reference in the Vision to sensitive development in rural areas being identified through Neighbourhood Plans which appears to pre-empt that the Local Plan Review will not plan for growth in rural areas. Axiom question this approach as it may be appropriate for the Local Plan Review to take strategic decisions about land allocations in rural areas to ensure the deliverability of the plan. 3.5 It is normal to have objectives associated with a Vision, setting out what the Local Plan Review should achieve to make the Vision a reality. It would be helpful if in the next iteration of the Local Plan Review, objectives are provided so it can be seen in greater detail what the Council are trying to achieve over the plan period.

Form ID: 2414
Agent: Axiom Great Barford Limited

I do not agree with this plan period

4.1 The NPPF (paragraph 22) sets out that the strategic policies for an area ‘should look ahead over a minimum 15-year period from adoption’. It is currently assumed that the Local Plan Review will be adopted in the winter of 2023, meaning the plan period should run until at least the end of 2038. 4.2 However, this assumes that the Local Plan Review is prepared and adopted in line with the expected timetable. Recent experience has shown that this can be difficult to achieve, and a plan end date of 2040 gives only 24 months flexibility in the production process to ensure the plan looks ahead 15 years from adoption. 4.3 Axiom would therefore advocate the plan looking ahead beyond 2040 to ensure this requirement can be achieved. Looking to 2045 would provide flexibility in the timetable and would be a more appropriate end date for the plan. 4.4 Irrespective of the end date of the Local Plan Review, it is considered that a plan period which starts at 2020 is appropriate given that this will be the base date for the evidence gathered to support the plan.

Form ID: 2415
Agent: Axiom Great Barford Limited

Brown – Urban based growth , Yellow – A421 based growth , Grey– Dispersed growth

5.1 The Issues and Options document outlines the current development strategy and correctly concludes that it will not deliver sufficient growth to meet the anticipated needs over the longer period of the Local Plan Review. 5.2 As set out under question 1, the Standard Methodology, and other material considerations, mean that the level of homes that need to be planned for in the longer term will increase. This means difficult decisions will need to be made locally about where development will be located and may mean some settlements taking more growth than previously envisaged. 5.3 A minimum of 15,000 new homes will need to be delivered over the Plan period (assuming a 2040 end date) meaning land for around 16,500 -18,000 new homes will need to be identified to ensure delivery. 5.4 It will be key that the strategy for accommodating this housing growth is coordinated with infrastructure investment and the strategy for meeting employment growth needs as part of an overall sustainable strategy for growth. 5.5 The Issues and Options document sets out 7 locations under consideration by the Council to accommodate growth: ● further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites; ● expansion of the Bedford / Kempston urban area; ● expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots; ● development along the A421 corridor; ● development around an East West Rail northern station; ● new settlements in locations with good accessibility; ● more dispersed development throughout the borough including the expansion of villages. 5.6 Given the level of growth that will need to be accommodated in the area, it is likely that the strategy will need to accommodate aspects of most of these options. However, there a several key points that Axiom believe need to be given consideration in refining the strategy. Neighbourhood Plan Growth 5.7 In line with policy 4S of the adopted Local Plan 2030, in a number of settlements it is likely that the Local Plan Review will need to make land allocations to deliver those homes expected to be allocated in the rural area through Neighbourhood Plans. 5.8 If this is the case, this should not prevent further growth being directed to these settlements where it can be accommodated sustainably and would help to meet the wider strategic objectives for the area. 5.9 Care will need to be taken to ensure that any growth deferred to Neighbourhood Plans is of a quantum that does not jeopardise the delivery of the overall development strategy should those plans be delayed. This will be particularly important if sites in the rural area are likely to make a greater overall contribution to meeting housing need, as may need to be the case given the constraints to development around the urban area of Bedford. 5.10 It will also be particularly important in locations such as Great Barford, which is in the A421 corridor, close to the potential East West Rail station, and therefore a strategically important location in the overall development strategy. 5.11 Whilst there may be scope for Neighbourhood Plans to allocate growth in some of the smaller settlements, this approach should only be relied on for development which is not integral to the overall growth strategy. A421 based growth 5.12 Axiom support a strategy which focuses a proportion of growth along the A421 corridor. This is the key route through the Borough which not only provides road access to the key centres of Milton Keynes and Cambridge but is also the focus of employment growth in the area. 5.13 As already noted, and referred to in the Issue and Options Paper, the A421 has seen considerable growth in employment floorspace over recent years given its location in both the Oxford to Cambridge Arc and the M1 corridor. It is expected that this demand will remain in the future, particularly for logistics given the ever-increasing emphasis on online sales. It therefore makes sense for a proportion of future housing growth to also be accommodated in the area where employment opportunities can be readily accessed. 5.14 Whilst employment growth is best located in the immediate vicinity of major road junctions and close to the urban area, there are rural settlements which are within the A421 corridor, with good access to employment opportunities where additional residential growth should be considered favorably. 5.15 Outside of the main urban area, Great Barford is one of the most appropriately located rural settlements to accommodate growth. It has good access to the A421 from where employment, leisure and retail opportunities can be accessed with ease. Importantly, it is also close to the proposed new East West Rail station to the east from where access to Cambridge will be possible. 5.16 Great Barford is physically separated from Bedford by the A421 and an area of flood risk which limits the potential for coalescence with the main urban area, meaning the settlements’ separate identities can easily be protected. 5.17 The adopted Local Plan 2030 directs 500 dwellings to Great Barford, to be allocated through the Neighbourhood Plan. Site assessments to support the Neighbourhood Plan have identified that there are several suitable sites in the village which, if all developed, could provide significantly more homes than currently proposed for allocation, which clearly demonstrates the potential of the area. 5.18 Axiom considers it important that future growth is focused along the A421 corridor and that the potential of rural settlements to contribute to the strategy for the corridor is recognised. Dispersed Rural Growth 5.19 Axiom support a development strategy which includes growth and development in a variety of settlements over the plan period. Whilst strategic scale growth and potentially new settlements will play a logical role in the strategy, deliverable growth in sustainable rural locations should be supported as part of a flexible strategy which does not overly rely on limited growth typologies. 5.20 In any dispersed strategy, priority should be given to growth in those rural settlements where development can contribute to achieving more than one objective of the Local Plan Review. 5.21 In the adopted Local Plan 2030, a ‘one size fits all’ approach was taken to the Key Service Centres, with 500 dwellings allocated to most of the identified villages based on future educational provision. Axiom suggest that this approach needs to be refined in the Local Plan Review and greater development focused on those rural settlements where growth is more sustainable and can help deliver the wider plan objectives. Urban Based Growth 5.22 Axiom support the role of urban based growth as part of the spatial strategy but not at the expense of the character of the urban fringe, particularly through development at higher densities around the edge of Bedford. 5.23 In certain locations and in some site-specific cases, higher density development may be appropriate but generally increasing densities in new development is likely to be detrimental to the character of the area. 5.24 The urban fringe is generally rural in character, particularly to the north of Bedford where there is limited separation between the urban area and a number of rural settlements. In these locations development should either be avoided or be of a scale and character commensurate with its setting. Rail related Growth and New Settlements 5.25 The response on these two growth typologies are combined as it is logical for any new settlement should be focused close to new rail station(s) on the East West Rail route to the north/north east of Bedford. 5.26 East West Rail will be one of the key infrastructure investments in the area over the plan period and it is important that advantage is taken of the improved accessibility the route will provide for new and existing residents. 5.27 Given the SWOT analysis in the Issues and Options document picks up on the fact that new settlements provide an opportunity to deliver sustainable transport links between new settlements and urban areas, it would be illogical for a new settlement proposal not to take advantage of the opportunities presented by East West Rail. 5.28 As identified in the SWOT analysis, new settlements also take a long time to plan and build and require significant investment in infrastructure. It is therefore important that any assumptions made about the delivery of new settlements are realistic and do not overestimate the short-to-medium term rate of housing delivery which would negate the need to make allocations elsewhere. 5.29 Experience shows that any housing delivery from a new settlement will be towards the back end of the plan period, with the majority of completions in years beyond 2040. This needs to be reflected in the development strategy to avoid any short-to-medium term land supply issues emerging which would be to the potential detriment of the overall growth strategy.

Form ID: 2417
Agent: Axiom Great Barford Limited

7.1 As already noted, the A421 corridor is the logical location for additional employment growth in Bedford Borough. There may also be opportunities for employment growth close to new rail stations and within new settlements should these form part of the future development strategy. 7.2 However, it should be recognised that many residents of Bedford Borough are likely to travel outside of the Borough for work given the proximity to major employment centres such as Cambridge and Milton Keynes and the ability to reach London via train. 7.3 It is therefore important to ensure that not only are employment sites located in sustainable locations within the Borough but that the overall development strategy recognises that many residents will travel for work. This means it is important the new homes are located in rural settlements with good highway access and in close proximity to rail stations.

Form ID: 2418
Agent: Axiom Great Barford Limited

6.1 Bedford already benefits from the upgraded A421 and a commitment to East West Rail within the next plan period. These are two pieces of key infrastructure that growth can be built around which is an advantage Bedford Borough enjoys when compared to neighbouring authorities. 6.2 It will be important that infrastructure is not just looked at on an authority by authority basis. Cross boundary working will be essential to ensure available funding is targeted on those areas and projects which will deliver the maximum benefit for the wider area. 6.3 In this regard, it will be important to liaise with neighbouring authorities and key stakeholders about infrastructure enhancements to the A1, M1 junction 13 and potential new railway stations north and east of Bedford, each of which could create development potential in Bedford Borough and the wider area. 6.4 It will also be important that the availability of services and facilities in individual settlements is properly assessed and considered as part of developing the spatial strategy. The ability for large-scale growth in rural centres to facilitate improved or new service provision at a local level should not be ignored. The lack of certain facilities in Key Service Centres can be remedied by new development which delivers homes along with new services and infrastructure for the local community.

Form ID: 2421
Agent: Axiom Great Barford Limited

8.1 It will be important that new residential development is located close to the key infrastructure which will provide access to the key economic centres to the east and west of Bedford. 8.2 It is also important that there is a variety of housing types and locations to satisfy the needs of the residents who are likely to choose to live in and around Bedford and travel elsewhere to work. Many of these residents may be in management or highly skilled work and have high expectations as to the location and type of home they desire. Many may not want to live in a dense urban extension on the edge of a town, preferring a more rural location with a different lifestyle. 8.3 This adds to the importance of considering locations within the development strategy where development is likely to be at a lower density than in the urban area and the rural lifestyle different to that offered in a town.

Form ID: 2423
Agent: Axiom Great Barford Limited

I agree

9.1 The NPPF (paragraph 20) makes it clear that planning measures to address climate change are a strategic matter. Therefore, the issue should be at the heart of decisions made about the spatial strategy. 9.2 Paragraph 149 of the NPPF states that Local Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood risk and biodiversity. 9.3 At a high level, this means development being avoided in areas which are more vulnerable to the impacts of climate change, such as in flood plains, and ensuring that adaption measures such as new green infrastructure are built into plans. 9.4 The location of development is therefore the key aspect of how the Local Plan Review should respond to climate change, rather than detailed guidance for developers. As has already been discussed, ensuring development is well located in relation to transport infrastructure will be a key consideration, as will ensuring there are opportunities for existing rural settlements to remain viable with an improved range of services and facilities for new and existing residents. 9.5 Whilst guidance on how the layout of development and the design of buildings would be helpful to ensure matters such as orientation, massing and landscaping contribute to minimising energy consumption, the setting of standards to be achieved by new development should be avoided unless they relate to the application of the Government’s technical standards, as required by paragraph 150 of the NPPF.

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